Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
We are committed to improving our practices to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 July 2019.
The University of Bath is a provider of educational and research services within the Higher Education sector. The University of Bath operates primarily from its city of Bath campus in the UK and is made up of three Faculties, sixteen Departments, one School and four Institutes collectively sharing the organisational mission to deliver world-class research and teaching, educating our students to become future leaders and innovators, and benefiting the wider population through our research, enterprise and influence. We currently have c. 18,700 students and c. 3,200 staff. We had an annual turnover in 2018/19 of £310m.
Our Supply Chains
The University’s supply chains are global and complex supporting and reflecting the diverse range of activities carried out through our teaching, research and commercial partnerships. Our expenditure with third party suppliers during 2018-19 can be categorised at a high level under the following categories (the percentage split is indicative):
- Estates and Construction 43.6%
- Professional Services 13.1%
- Laboratory & Medical 10.2%
- IT & Telecoms 7.3%
- Library 6.1%
- Utilities 5.1%
- Travel & Transport 4.2%
- Janitorial & Security 3.7%
- Catering 2.8%
- Miscellaneous 2.2%
- Furniture & Furnishings 0.7%
- Office Supplies & Printing 0.6%
- Sports 0.4%
The University is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery-free, we operate and regularly review workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues. Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chains.
Some of the University policies that support our approach to tackling modern slavery and human trafficking include:
Dignity and Respect Policy
This promotes a working and learning environment which will be stimulating and supportive and free of harassment, bullying and victimisation; where individuals are confident, if they bring a complaint in good faith, that the matter will be dealt with according to the agreed procedures without fear of subsequent victimisation or disadvantage. This policy applies to all staff (including casual and voluntary workers), honorary and visiting staff, volunteers and students and third parties (e.g. contractor, client or customer of the University).
Equality and Diversity Policies
This details how the University can be most effective in its impact on equality, diversity and inclusion and the elimination of harassment and discrimination (including our ‘#neverok’ campaigns).
Public Interest Disclosure Policy (Whistleblowing)
The University of Bath is committed to maintaining the highest standards of honesty, openness and accountability and to conducting its business in a responsible way. The policy encourages employees to raise their concerns in a responsible way where there is malpractice (that is, illegal, improper or negligent behaviour) or wrongdoing within an organisation and, where they do so, protects those employees from reprisal.
Health & Safety and Health & Wellbeing Policies
This sets out the expectations on employees, students, and contractors to support the University’s efforts to provide a safe and healthy workplace and to meet their own individual duty of care to others.
This aims to ensure the safety and welfare of children and adults at risk whilst on the University's premises or while engaging in activities controlled by the University. The University of Bath is represented on the Operations Board of the Bath and North East Somerset Community Safety and Safeguarding Partnership whose remit includes Modern Slavery issues.
Recruitment policy (employment checks)
This ensures our recruitment processes are non-discriminatory and that staff have a right to work in the UK, with checks made before they start work and that all immigration requirements are met as specified by UK Visas & Immigration (UKVI).
Due Diligence Processes for Slavery and Human Trafficking
We continue to evolve our category management approach to managing expenditure with third party suppliers to the University, which allows us to manage supply chain risk by category and by supplier where necessary. Periodic reviews of our supply chains by category allow the risks associated with modern slavery and human trafficking to be considered, identified and managed.
The University’s standard contractual terms and conditions used when procuring goods, service and works include provisions that embed the requirements of the Modern Slavery Act and provide the University with the powers to request information from our suppliers on the nature of their supply chains where necessary.
We highlight our commitment to tackling modern slavery and human trafficking to all new suppliers and seek confirmation that new suppliers have no convictions under the Modern Slavery Act and are compliant with the Act.
The University has developed a Responsible Procurement Code of Practice, which documents our aims related to the environmental, social, economic and ethical impact, which includes modern slavery and human trafficking, when procuring all goods, services and works. This also makes it clear that all suppliers to the University are expected to comply with the principles of Responsible Procurement.
We are committed to using and selling ethically-sourced food in our hospitality outlets and catering services. The University has been awarded the Gold Award for Best Fairtrade University, in recognition of our continued commitment to Fairtrade products, promotions and events, as well as our efforts over Fairtrade Fortnight. Fairtrade standards explicitly prohibit the use of forced labour and child labour. Independent auditors are used to look for evidence of abuse or discriminatory labour practices by employers, which are often indicators of modern slavery.
We follow the Public Contract Regulations when procuring goods, services and works. When the estimated value of the contract exceeds the EU value thresholds we ask all applicable bidding suppliers to confirm their compliance with the Modern Slavery Act.
The Living Wage Foundation has accredited the University as a Living Wage Employer. This commits the University to ensuring that staff salaries keep pace with the cost of living. As part of this initiative we also request that relevant suppliers to the University also pay their staff the National Living wage or greater when delivering services to the University.
The University utilises a range of available framework agreements established by the buying consortium SUPC. This consortium is committed to ensuring modern slavery and human trafficking does not exist within their supply chains and requires suppliers operating within high risk industries to commit to the Base Code of the Ethical Trading Initiative (ETI). The ETI Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice, requiring that employment is freely chosen; freedom of association and the right to collective bargaining are respected; working conditions are safe and hygienic; child labour shall not be used; living wages are paid; working hours are not excessive; no discrimination is practised; regular employment is provided; and no harsh or inhumane treatment is allowed.
The University also can seek expert guidance and support from Electronics Watch via our relationship with SUPC where the purchasing of electronic equipment is concerned. Electronics Watch brings together public sector buyers and civil society organisations in electronics production regions with experts in human rights and global supply chains. They guide public procurement demand for decent working conditions in electronics supply chains and provide capacity for public buyers to follow up on contractual demands through worker-driven monitoring which helps workers to voice complaints and contribute to solutions.
All professional procurement staff are trained in Ethical Procurement by the Chartered Institute of Procurement & Supply.
We will continue to evolve our working practices to ensure that the risks associated with modern slavery and human trafficking are managed effectively. In particular, during the 2019-20 financial year we aim to improve in the following areas:
All professional procurement staff will undertake refresher training on Ethical Procurement provided by the Chartered Institute of Procurement and Supply in order to ensure their knowledge of the subject is maintained.
We will explore options to provide comprehensive training on combating modern slavery and human trafficking in our supply chains to our community of requisitioners.
We will seek to learn from and contribute to the academic knowledge that exists within the University on the topic of modern slavery and human trafficking within supply chains.
We will develop and disseminate detailed information on combating modern slavery and human trafficking to all University staff. We will continue to develop our knowledge and understanding of the high risk industries by working closely with our key suppliers and support organisations such as Electronics Watch.
We will identify other buying organisations that have adopted recognised good practice when tackling modern slavery and human trafficking in their supply chains and seek to learn from their experience.
We will continue to promote the University Public Interest Disclosure Policy (Whistleblowing) reiterating its role in reporting instances of suspected modern slavery or human trafficking throughout any part of the University operation.
We will engage with the student body to raise awareness, solicit their views, and seek support in developing further positive steps related to tackling modern slavery and human trafficking.
Approved by Pamela Chesters, Chair of Council, on 23 January 2020